The Blood Brothers Essay Example for Free

The Blood Brothers Essay Willy Russell writes entertaining drama about believable characters and champions the cause of the socially disadvantaged. With reference to the historical and social context of Blood Brothers, analyse the accuracy of this statement. Blood Brothers is a musical play written in the 1980s during a recession in a United Kingdom. Written by Willy Russell, the play revolves around the subject of social class, which is definitely a constant theme throughout the play. Set in Liverpool, the story centres on a set of twins that are separated at birth with both mothers desperately trying to keep them apart in vain. In this essay I will analyse the accuracy of the statement above and relate to it throughout this essay. Russell uses a variety of techniques to make Blood Brothers an entertaining piece of drama. One way he portrays the story in an effective way to engage the audience, is by using dramatic tension. Dramatic tension is used when Mrs Lyons blackmails Mrs Johnstone to not tell anyone that the two boys are brothers, by using her fear of superstition. They say they say that if either twin learns that he was once a pair, they shall both immediately die. You wont tell anyone about this Mrs Johnstone; because of you do you will kill them. This section of the play is an excellent example of dramatic tension as it creates suspense and makes the audience sympathise with Mrs Johnstone. Dramatic irony is also another technique Russell uses to entertain the audience. The section of the play where Mickey and Edward meet as young children is great example if this. Ey, we were born on the same day that means we can be blood brothers. Do you want to be my blood brother, Eddie? The audience (and the narrators) know the full story, and know that Mickey and Eddie dont need to be blood brothers because they are already real brothers, and share the same blood. This frees up the audience to observe the implications of the characters actions and having an advantage over the story, by knowing the full plot. Blood Brothers is a musical play, and the songs involved, play an important role throughout. As well as keeping the audience entertained the songs gives us character insight, provides extra information, and carries along the storyline. The songs emphasise and highlight key moments during the play, and make the audience aware of their importance. Techniques such as foreshadowing are made clearer, and the music portrays certain moods making characters emotions and thoughts clearer. An interesting technique Russell has used at the beginning of the play is by using a prologue. This is a very effective way to engage the audience, by giving the audience an insight into the plot for example of one womb born on the self same day, how one was kept and one given away It brings forth questions in the audiences mind and the answers are revealed as the story unfolds. It frees up the audience to speculate the storyline and how the ending came to be. This intricate plot structure shows how the characters actions have severe consequences throughout the story An did you never hear how the Jonstones died, never knowing that they shared one name Foreshadowing is fantastic technique that Russell uses successfully in the prologue and throughout the play. Foreshadowing is when events that happening later on in the play are foretold or hinted by earlier events. The prologue makes foreshadowing possible because the end is revealed to the audience and makes them look for possible omens of this during the story. There are many great examples of this throughout the play, especially in the beginning when the children are playing with toy guns. But you know that if you cross your fingers, and if you count from one to ten, you can get up off the ground again, it doesnt matter the whole things just a game. The reference to guns and its just a game is repeated throughout the play, and relates to the twins death at the end as both of them are shot. At the end of the play its not just a childish game, and the reality becomes too difficult for the characters to deal with. The quotation implies a long for childish innocence from all the characters, and a cry for help from the tragic ending. Although the outcome of the Blood Brothers storyline is tragic, Russell adds comedy and humour throughout. When the boys first meet, an example of Russells humour occurs; So they took him to the hospital an put a plate in his head A plate? A dinner plate? Russell lightens the mood by injecting humour into a scene full of tension and irony. The comedy in the play makes Blood Brothers a more enjoyable and entertaining piece of drama for the audience to watch. By adding this childlike humour into the play, it shows that Russell can invent realistic and believable characters which make the audience more likely to sympathise with the characters. As well as having a great understanding of young children, Russell also has an understanding of adolescents as well. Linda, I wanna kiss y an kiss y but I dont know how to tell y because Ive got pimples an me feet are too big an me bum sticks out

The Nuclear Power Debate Essay -- essays research papers fc

The Nuclear Power Debate   Ã‚  Ã‚  Ã‚  Ã‚  In 1953, nuclear energy was introduced into America as a cheap and efficient energy source, favoured in place of increasingly scarce fossil fuels which caused air pollution. Its initial use was welcomed by the general public, as it was hoped to lower the price of electricity, and utilise nuclear power for it's potential as a resource, not a weapon. However, as people became aware of the long term dangers involved in storing nuclear waste, it's use was criticised. Two accidents, at Three Mile Island and Chernobyl, demonstrated to the world the enormous risks involved in producing nuclear power.   Ã‚  Ã‚  Ã‚  Ã‚  Nuclear power provides 17% of the world's electricity but coal is the main source, making up 39%. However, fossil fuels such as coal, require greater quantities to produce the equivalent amount of electricity produced from Uranium. The use of nuclear power opposed to burning fossil fuels has reduced carbon dioxide emissions by 2 billion tonnes per year, minimising the global warming effect on the atmosphere. Carbon dioxide is responsible for half of man made gases contributing to the Greenhouse Effect, and has sparked action from the UN Intergovernment Panel on Climate Change. Their consensus is a concern for the environment in the next century if fossil fuels continue to be used, even at present global levels. The Panel claims that for carbon dioxide to be stabilised to safe levels, a 50-80% reduction in all emissions would be ...

Alternative Ending To Catcher in the Rye Essay

Anyway, I really did go home after the carrousel. First, Phoebe and I walked out of the park and took the bus to Grand Central, to get my god dam Gladstone’s out of the strong box there. Though it had stopped hammering down, I was still pretty wet. Boy, it really came down like a madman. I still had ‘Phoebe’s’ red hunting hat on, it was soaking wet though. I didn’t care though. â€Å"I’m glad we’re both going home now, Holden†, she said. â€Å"I’m just ready to get this over with†, I said, â€Å"Mom and dad will cry.† â€Å"Don’t worry, Holden. It’ll be okay†, Phoebe said. She squeezed my hand which she was holding and smiled. It just about killed me. We had most of Phoebe’s Christmas dough, so we got my Gladstone’s, and took the bus to 72nd street. There were a bunch of kids at the back of the bus. They were all horsing around, laughing and all. We sat next to them. We took up a lot of room, since we had my two suitcases, plus my old suitcase with Phoebe’s stuff in it. I heard some kid say, â€Å"Phoebe, your brother found you!† I looked across the bus. It was that kid I met in the park yesterday, the girls who roller skates I’d tightened and all. â€Å"Holden’s coming to see me in the play†, she said to the girl. She tugged my arm, â€Å"This is my brother Holden, Holden, this is Susie. She’s in the play too!† â€Å"Yes†, Susie said, â€Å"It should be really great†. She was so polite. I really liked her. I usually like Phoebe’s friends when I first meet them. Phoebe and Susie helped me get my mind off of how I was about to face my parents. I was worried about my mom. I tried not to think of how hysterical she’d get. Phoebe said mom and dad were coming home at around 7. It was 4 now. We got off the bus at 72nd street, said goodbye to Susie and all, and then walked home. â€Å"How are Mr. and Mrs. Antolini?† she asked me. â€Å"They’re doing pretty good†, I said. Of course I would never tell her what really happened. I still couldn’t believe it. Had he always liked me in a flirty way? We got home, and I took my suitcases into my room and I lay down on my bed. I was pretty tired. All of a sudden i got to thinking about Pencey. I wondered what they were all saying about me back there. I started thinking maybe I was wrong, leaving so suddenly after that god dam little tiff with Stradlater. He’s really not a bad guy. In fact, I sort of missed him. I’ll give old Jane a bell tomorrow, if it’s not too crazy here. So I unpacked a few things in my room, and smoked all of my cigarettes. I was so god dam nervous. Around 7 o’clock, mom and dad walked in together. At the time, I was right there in the hallway, so they saw me right away. I really didn’t care if they yelled at me. I felt numb and empty inside. I was really hungry, but too worried to eat. If you want to know the truth, I was in pretty bad shape. Even though I changed and washed before mom and dad came home, I felt that I must have looked a state. I hadn’t shaved in a few days. Anyway, they looked all dressed up and nice when they came through the door. â€Å"Holden! What’s going on? What are you doing here? Its’ Tuesday†, my dad said. I took a deep breath, and then started coughing all over the place. Christ, what a time to have a coughing fit ey? I finally cleared my throat. â€Å"Well†, I said, â€Å"I†¦I got kicked out again. I’m really sorry† â€Å"Damn it, Holden! I can’t take it anymore!† Dad yelled. Mom had already started sobbing. I felt awful. Seeing Mom cry really killed me. â€Å"Holden, what the hell is wrong with you!? I paid a ton of money to send you to these schools and all you do is get kicked out every god dam time! I know you’re not stupid! You can pass these classes! I know it’s that you’re not applying yourself!† Boy was he mad. His face was all red, and all these veins were sticking out in his neck. I was kinda scared that he would hit me. We’re a pretty non-violent family. I was thinking about Allie the whole time Dad was yelling at me. I don’t know how long the whole thing lasted. â€Å"Damn it, Holden, you’ve really pushed my buttons this time! Look at how well DB and Phoebe are doing. Can’t you follow their lead?† Mom was just sobbing the whole time that the argument was going on. I started drifting off again, I thought about Mr. Antolini. I could be there now, having an intellectual conversation with him, smoking a cigarette. I kept thinking about him patting me on the head. Does he look at me as another son figure? Or does he have feelings for me? Or was he just really drunk? It didn’t seem right at all. When I got there, he should have noticed how tired I was and just let me sleep. So, Dad was kept on yelling at me and sent me to my room. I walked into my room, shut the door, and lay down on my bed again and lit a cigarette that I found in my hounds tooth jacket pocket. I hardly ever see Dad this mad. I heard my mom crying in their bedroom, and my father trying to comfort her. I started thinking of the military school. I knew I’d hate it there, even more than the other schools I’d been to. The next thing I knew, I was sort of crying. Normally I’m not a huge crier, but here I was, crying my god dam eyes out. I heard a little knock at the door, and old Phoebe came in. â€Å"I heard you crying, don’t worry Holden, everything will blow over†. She sat on the side of my bed and hugged me. Trust Phoebe to do something phony like that, but all the same, it was kinda cute. Phoebe went to bed at around 9 o’clock and I was still awake by 11. I couldn’t sleep. I felt kinda weak, and I kept coughing like a madman. That’s about it, that’s all I’m gonna tell you. I could go on and tell you about the military school and Phoebe and all. But I think I told too much already.

Business Essays - International Trade Law - Free Essay Example

Sample details Pages: 14 Words: 4296 Downloads: 10 Date added: 2017/06/26 Category Business Essay Type Argumentative essay Did you like this example? International Trade Law International Trade Law for Business (a) In looking to critically discuss the view à ¢Ã¢â€š ¬Ã…“the bill of lading is the essential document in the international contract of sale has no other document performs the functions of the bill of ladingà ¢Ã¢â€š ¬Ã‚  the bill of lading is considered the most important document because it is recognised by law as the symbol of the goods described in it to guard against the risk of non-delivery by the ship-owner, the CIF (à ¢Ã¢â€š ¬Ã‹Å"cost, insurance, freightà ¢Ã¢â€š ¬Ã¢â€ž ¢) contract requires the seller to take out a policy of marine insurance on which the buyer may sue. This is because, between the seller of the goods and the buyer of exchange, the delivery of the bill of lading is by way of pledge, and the security of the buyer of exchange is, until acceptance by the buyer on delivery to them of the documents, the liability of the seller as drawer of the bill of exchange with the bill of lading as collateral security. As a result, a person who holds both the bil l of lading and a marine insurance policy on the goods is, for business purposes, in as good a position as if the goods were actually in their possession, subject only to the ship ownerà ¢Ã¢â€š ¬Ã¢â€ž ¢s lien Therefore, the delivery to the buyer of a bill of lading and an insurance policy on the goods together with the invoice which identifies them is treated both commercially and legally as satisfying the contractual obligations of the seller under a CIF contract. Don’t waste time! Our writers will create an original "Business Essays International Trade Law" essay for you Create order However, the invoice, that normally debits the buyer with the agreed price is required partly to identify the goods sold with the goods shipped and insured to complete the record of the transaction and to show the price of the goods and to enable the buyer to raise money on their security more easily. This is because, in some trades, it is common for the price of the goods itself to vary with movements in the market according to an agreed formula à ¢Ã¢â€š ¬Ã¢â‚¬Å" e.g. the Plattà ¢Ã¢â€š ¬Ã¢â€ž ¢s formula used in the oil trade. On this basis, there are a number of requirements for the acceptable tender of a bill of lading because it is the duty of the seller to procure a contract of carriage is satisfied if they procure a contract of carriage which conforms with any stipulations agreed in the contract of sale and which is otherwise reasonable and acceptable in the trade at the time when it is made. Therefore, this duty has been examined in the courts in the context of a num ber of requirements. First, in the absence of a stipulation or custom in the particular trade to the contrary, the contract of carriage must be one which will give the holder a right of action against the carrier in respect of the goods from the time of shipment until arrival at destination. However, there appears to be no authority as to whether the seller is, in the absence of any express term to this effect in the contract of sale, under a duty to tender a bill which clearly identifies the carrier, although it is clear that the buyer may well have an interest in the identity of the carrier on whom the care of goods at buyerà ¢Ã¢â€š ¬Ã¢â€ž ¢s risk depends. Therefore, as to whom the buyer can sue on the contract of carriage contained in the bill of lading tendered by the seller will depend largely on the manner in which the bill of lading is signed. Nevertheless, it is also a requirement of an acceptable tender of a bill of lading the document tendered must be a bill of ladi ng in transferable form to allow the buyer to transfer the right to claim delivery of the goods from the carrier through transfer of the bill. Moreover, the bill of lading must cover only the goods which are the subject matter of the contract of sale, but in the absence of an express term in the contract of sale stipulating for the tender of more than one bill of lading, the seller is both entitled and bound to tender one bill of lading, at any rate when the goods sold are all of the same type. Furthermore, the bill of lading must be a clean bill free from any annotation or clause qualifying the statement à ¢Ã¢â€š ¬Ã‹Å"shipped in good order and conditionà ¢Ã¢â€š ¬Ã¢â€ž ¢. Also, as to whether or not a bill of lading stating that the goods have been à ¢Ã¢â€š ¬Ã‹Å"received for shipmentà ¢Ã¢â€š ¬Ã¢â€ž ¢ and issued before the goods are placed on board by the carrier who is to carry them is a bill of lading within the requirements of a CIF contract is still a matter of some doubt. As well as this, as to whether or not a bill of lading stating the carrier can deviate from the voyage stipulated for in the contract of carriage is also still doubtful. Furthermore, as to whether or not a clause in the bill of lading stating that the goods will or may be transshipped is valid will depend on the terms of the contract and arguably whether or not the bill of lading imposes liability on the contractual carrier from the port of loading to the port of discharge under the contract of carriage. Finally, a bill of lading stating that freight has yet to be paid at destination (a à ¢Ã¢â€š ¬Ã‹Å"freight collectà ¢Ã¢â€š ¬Ã¢â€ž ¢ bills of lading) constitutes good tender so long as the contract of sale does not prohibit tender of such a document and the sum of the freight payable at destination is deducted from the commercial invoice. However, the bill of lading must not only comply with the requirements set out above but it must also accurately evidence the contract of carriage because the buyer is not obliged to investigate, or to accept assurances about, the contract of carriage outside the bill of lading. Moreover, the buyer is also not obliged to accept a bill varied after issue, or, it seems, one altered before issue other than to correct a minor clerical error. This is because the bill of lading must be procured on shipment that is to say as soon as is reasonably possible after the goods have been delivered to the carrier for carriage to the agreed destination. Therefore, it is to be understood no other document, for example a delivery order, a non-transferable bill of lading or a sea waybill or a ships release, will, in the absence of special provision or custom, amount to a good tender under the contract. Moreover, a à ¢Ã¢â€š ¬Ã‹Å"received for shipmentà ¢Ã¢â€š ¬Ã¢â€ž ¢ bill of lading is also of some interest because it states goods have been received by the carrier for shipment on board, but does not state the goods have actually been shipped on board, since it is a matter of some doubt whether such a bill of lading can be tendered by a CIF seller. This is because such tender is valid if sanctioned by the agreement of the parties or by usage of the particular trade and, where the contract expressly prohibits the tender of such a document, the seller is bound to tender a bill of lading stating that the goods have been shipped on board. But, in cases where the contract of sale is silent as to the tender of à ¢Ã¢â€š ¬Ã‹Å"received for shipmentà ¢Ã¢â€š ¬Ã¢â€ž ¢ bills, it is not yet clear whether the seller is entitled to tender such a document. This is because, save for a trade custom to the contrary, the seller is bound to tender a bill of lading in transferable form and, given that a à ¢Ã¢â€š ¬Ã‹Å"received for shipmentà ¢Ã¢â€š ¬Ã¢â€ž ¢ bill of lading has been held not to be transferable, given the common currency of à ¢Ã¢â€š ¬Ã‹Å"received for shipmentà ¢Ã¢â€š ¬Ã¢â€ž ¢ bills of lading in internationa l trade, and, given that such bills of lading are now arguably recognised as transferring to the buyer rights of suit against the carrier under a contract of carriage, such bills of lading constitute good tender under CIF contracts which do not prohibit such tender Furthermore, where a CIF buyer with rights of suit against the carrier transferred to them by the seller through the operation of the Carriage of Goods Act 1992 suffers loss as a result of the deviation by the carrier from the voyage agreed in the contract of carriage between the buyer and the carrier, the buyer may pursue any remedies against the carrier afforded by that contract. But it is doubtful whether a buyer can reject a bill of lading against the seller simply because it seeks to give the carrier a liberty to deviate. Nevertheless, where the contract of sale stipulates shipment must be direct, it would seem a buyer can reject a bill of lading containing a liberty to deviate clause. Also, where the contra ct of sale fails to stipulate as much, or where it expressly envisages shipment may be direct or indirect, the buyer can reject a bill of lading granting the carrier a liberty to deviate where the extent of the liberty is uncertain because the clause itself is not printed on the bill. Moreover, where the extent of the liberty is certain and wide, it has been said that the buyer can reject the bill of lading Therefore, given the currency of wide liberty to deviate clauses in bills of lading and given the protection afforded to the buyer by the rules regulating the contract for the carriage of goods by sea, it would seem, however, equally arguable a buyer could not reject a bill of lading In conclusion, in looking to critically discuss the view that à ¢Ã¢â€š ¬Ã…“the bill of lading is the essential document in the international contract of sale has no other document performs the functions of the bill of ladingà ¢Ã¢â€š ¬Ã‚ , despite some discrepancies evidenced in this discus sion, the bill of lading is the most important document because the symbol of the goods described in it to guard against the risk of non-delivery by the ship-owner. This is because, between the seller of the goods and the buyer of exchange, the delivery of the bill of lading is by way of pledge, and the security of the buyer of exchange is, until acceptance by the buyer on delivery to them of the documents, the liability of the seller as drawer of the bill of exchange with the bill of lading as collateral security. Therefore, someone holding both the bill of lading and a marine insurance policy on the goods is, for business purposes, in as good a position as if the goods were actually in their possession so the delivery to the buyer of a bill of lading and an insurance policy on the goods together with the invoice which identifies them is treated both commercially and legally as satisfying the contractual obligations of the seller under a CIF contract. (b) In looking to adv ise the carrier with regard to any liability owed to Najeeb to begin with it must be recognised that under a CIF contract the duty of the seller is actually accomplished when the goods described in the contract of sale are put on board a ship bound for the destination specified in the contract or through the purchase of such goods already afloat. Accordingly, the contract is, in a commercial sense, an agreement for the sale of goods to be performed by delivery of documents or a sale of documents representing goods, the seller having obligations in law regarding both the goods and the documents covering them. This means that it is generally understood that the property in the goods (i.e. the 500 bags of flour) will commonly pass when the documents which represent the goods are tendered in exchange for the price. However, the carrier must be advised that if, in accordance with the general principle, property may, if the contract shows such an intention, pass at some different stage , as on shipment or on consignment of the documents to the buyer, then the contractual link between the buyer (Najeeb) and the ship-owner, arises out of the contract of carriage. This is because the contract is an agreement for the sale of goods to be performed by delivery of documents, or a sale of documents representing goods, with the seller having obligations in law regarding both the goods and the documents covering them Accordingly, this is in keeping with the fact that an agreement for the carriage by sea of a cargo or for the use of a ship for a voyage or series of voyages or for a specified time is normally contained in or evidenced by a bill of lading On this basis, it must be recognised that the carrier needs to be advised the bill of lading is considered the most important document in this kind of contract. This is because of the fact that it is recognised by law as the symbol of the goods described in it to guard against the risk of non-delivery by the ship-owner, the CIF (à ¢Ã¢â€š ¬Ã‹Å"cost, insurance, freightà ¢Ã¢â€š ¬Ã¢â€ž ¢) contract requires the seller to take out a policy of marine insurance on which the buyer may sue. Therefore, where goods for which a bill of lading has been signed have been shipped, the property in the goods may, so long as the voyage continues, be transferred by a transfer of the bill of lading, made according to its tenor, and with the intention of passing the property in the goods However, the transfer may be made with the intention of passing the property conditionally, or for a specific purpose only, and not for the purpose of passing the property outright in the goods, as where the bill of lading is transmitted with a bill of exchange drawn on the buyer. This means the carrier needs to be advised that the voyage is deemed to continue so long as the goods are in the custody of the master of the vessel, or of some person on his behalf and until possession of the goods has been taken by or on behalf of th e person entitled to demand it. The carrier also needs to be advised that this is in keeping with the fact there are a number of requirements for the acceptable tender of a bill of lading. This is because of the fact that it is the duty of the seller to procure a contract of carriage is satisfied if they procure a contract of carriage which conforms to any stipulations agreed in the contract of sale and which is otherwise reasonable and acceptable in the trade. Therefore, the carrier must be advised that, in the absence of a stipulation or custom in the particular trade to the contrary, the contract must give the holder a right of action against the carrier in respect of the goods from shipment until they arrive at their destination But as to whom the buyer can sue on the contract of carriage contained in the bill of lading tendered by the seller will depend largely on the manner in which the bill of lading is signed. Moreover, whilst the document tendered must be a bill of lading in transferable form to allow the buyer to transfer the right to claim delivery of the goods from the carrier through transfer of the bill, the bill of lading must only cover the goods subject to the contract of sale. Nevertheless, with particular reference to the facts of this case, the carrier must be advised that the bill of lading must be a clean bill free from any annotation or clause qualifying the statement à ¢Ã¢â€š ¬Ã‹Å"shipped in good order and conditionà ¢Ã¢â€š ¬Ã¢â€ž ¢. Also, as to whether or not a bill of lading stating that the goods have been à ¢Ã¢â€š ¬Ã‹Å"received for shipmentà ¢Ã¢â€š ¬Ã¢â€ž ¢ and issued before the goods are placed on board by the carrier who is to carry them is a bill of lading within the requirements of a CIF contract is still a matter of some doubt. But the bill of lading must not only comply with the requirements set out above but it must also accurately evidence the contract of carriage because the buyer is not obliged to invest igate, or to accept assurances about, the contract of carriage outside the bill of lading. Moreover, the buyer is also not obliged to accept a bill varied after issue or one altered before issue other than to correct a minor clerical error because the bill of lading must be procured on shipment. Accordingly, the carrier needs to be advised that the fact that Jac offered the carrier an indemnity if a clean bill of lading was issued meant that between the seller of the goods and the buyer of exchange, the delivery of the bill of lading is by way of pledge, and the security of the buyer of exchange is, until acceptance by the buyer on delivery to them of the documents, the liability of the seller as drawer of the bill of exchange with the bill of lading as collateral security. Therefore, whilst the words à ¢Ã¢â€š ¬Ã‹Å"shipped in good order and conditionà ¢Ã¢â€š ¬Ã¢â€ž ¢ do not import a warranty, they do amount to a representation of fact the goods were shipped in apparent good order and condition. This means that if an indorsee changes their position on the faith of this representation and afterwards sues the ship-owner for delivering the goods in bad condition, the shipowner (at any rate where they were not induced to make the statement by fraud) will be estopped from denying that the goods were shipped in apparent good order and condition in keeping with the 50 damp bags and 100 bags which contained tiny holes and some of the sugar had escaped through the holes during the journey that should have been recognised when the sugar was being loaded. Nevertheless, the carrier must still be advised that estoppel will be available to the indorsee or holder only if they have changed their position on the faith of the representation and the fact that the indorsee has taken up and pays for the bill of lading and other shipping documents under a CIF contract is prima facie evidence that they changed their position on the faith of the representation in the bill o f lading. Moreover, it must also be shown in looking to advise the carrier that those relying on the estoppel satisfied the court that the defect in question was one which would have been apparent to the shipowner on reasonable examination and the statement upon which the alleged estoppel is founded must be clear and unqualified, otherwise the whole case of estoppel against them fails. Furthermore, the carrier also needs to be advised that if, however, the contract of sale precludes the indorsee from rejecting the shipment, although giving them a right to claim damages for the defects in the goods, they will not have changed their position by taking up the documents. But it must also be recognised that the carrier also needs to be advised that where the Hague-Visby Rules apply, by virtue of the Carriage of Goods by Sea Act 1971, and the receiver is taking advantage of the estoppel in the Hague-Visby Rules at Article III, rule 4, there is no need for them to prove that they relied upon the statement. Nevertheless, the ship-owner will not be estopped from proving that the internal condition of the goods was bad so as to rot the bags in this case. Moreover, in any contract for the carriage of goods by sea to which the Hague-Visby Rules apply, by virtue of the Carriage of Goods by Sea Act 1971, neither the carrier nor the ship is responsible for loss or damage arising or resulting from insufficiency of packing. However, by way of conclusion, it must be recognised that in the case of contracts for the carriage of goods by sea, to which the Hague Rules or the Hague-Visby Rules apply, the carrier also needs to be advised that the carrier and the ship are discharged from all liability whatsoever in respect of the goodsregarding loss or damage unless à ¢Ã¢â€š ¬Ã‹Å"suità ¢Ã¢â€š ¬Ã¢â€ž ¢ is brought within one year after delivery of the goods or the date when the goods should have been delivered. But the suit may be brought in any competent jurisdictio n, not necessarily in the jurisdiction where the matter is ultimately decided; and the suit must be brought in the name of a party who has title to sue(under an agreement known as the Gold Clause Agreement, entered into between British shipowners and underwriters). Nevertheless, the carrier also needs to be advised that the one-year period may be extended if the parties so agree after the cause of action has arisen, so that it may be argued that the carrier may even have had a role in determining whether they are liable. Bibliography à ¢Ã¢â€š ¬Ã‹Å"Halsburyà ¢Ã¢â€š ¬Ã¢â€ž ¢s Lawà ¢Ã¢â€š ¬Ã¢â€ž ¢s of Englandà ¢Ã¢â€š ¬Ã¢â€ž ¢ Butterworths (2007) Table of Cases Albacruz (Owners) v. Albazero (Owners), The Albazero [1974] 2 All ER 906; affd [1975] 3 All ER 21, CA; revsd [1977] AC 774, HL American Hoesch Inc Riblet Products Inc v. SS Aubade etc Maritime Commercial Corpn Inc [1971] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 423 Amis, Swain Co v. Nippon Yusen Kabushiki Kaisha (1919) 1 Ll L Rep 51 Arnhold Karberg Co v. Blythe, Green, Jourdain Co [1916] 1 KB 495, CA Arnold Otto Meyer NV v. Aune [1939] 3 All ER 168 Bangladesh Export Import Co Ltd v. Sucden Kerry SA [1995] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 1 Barclays Bank Ltd v Customs Excise Comrs [1963] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 81 Bateman v. Green King (1867) IR 2 CL 166 Bergerco USA v. Vegoil Ltd [1984] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 440 Burdick v. Sewell (1884) 13 QBD 159, CA Burstall Co v. Grimsdale Sons (1906) 11 Com Cas 280 Canada Dominion Sugar Co Ltd v. Canadian National (West Indies) Steamships Ltd [1947] AC 46, PC Cargill International SA v. Bangladesh Sugar Food Industries Corpn [1996] 4 All ER 563 Cargill International SA v. CPN Tankers (Bermuda) Ltd, The Ot Sonja [1993] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 435, CA Colin Shields v. W Weddel Co Ltd [1952] 2 All ER 337, CA Compania Colombiana de Seguros v. Pacific Steam Navigation Co [1965] 1 QB 101 Compania Naviera Vasconzada v. Churchill Sim [1906] 1 KB 237 Comptoir dAchat et de Vente du Boerenbond Belge SA v. Luis de Ridder Lda, The Julia [1949] AC 293 Connolly Shaw Ltd v. A/S Det Nordenfjeldske D/S (1934) 49 Ll L Rep 183 Continental Fertilizer Co Ltd v. Pionier Shipping CV, The Pionier [1995] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 223 Cremer v. General Carriers SA [1974] 1 All ER 1 Cummins Sales Service Inc v. Institute of London Underwriters Deutsche Dampfschiffahrt Gesellschaft Hansa, The Goldenfels [1974] 1 Lloydà ¢Ã¢ ‚ ¬Ã¢â€ž ¢s Rep 292 (US 5th Cir) DI Henry Ltd v. Clasen [1973] 1 Lloyds Rep 159, CA Diamond Alkali Export Corpn v. Fl Bourgeois [1921] 3 KB 443 Finska Cellulosaforeningen v. Westfield Paper Co Ltd [1940] 4 All ER 473 Foreman Ellams Ltd v. Blackburn [1928] 2 KB 60 Fort Sterling Ltd v. South Atlantic Cargo Shipping NV, The Finnrose [1994] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 559 Glynn v. Margetson Co [1893] AC 351, HL Goulandris Bros Ltd v. B Goldman Sons Ltd [1958] 1 QB 74 Hansson v Hamel Horley Ltd [1922] 2 AC 36, HL Hindley Co Ltd v. East Indian Produce Co Ltd [1973] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 515 Hispanica de Petroleos SA Cia Iberica Refinadera de Petroleos SA v. Vencedora Oceanica Navegacion SA, The Kapetan Markos NL [1986] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 211, CA Houlder Bros Co Ltd v. Public Works Comr [1908] AC 276, PC Interbulk Ltd v. Ponte Dei Sospiri Shipping Co, The Standard Ardour [1988] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 159 James Finlay Co Ltd v. Kwik Hoo Tong Handel Maatschappij NV [1928] 2 KB 604; affd [1929] 1 KB 400, CA Kum v. Wah Tat Bank Ltd [1971] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 439, PC Landauer Co v. Craven Speeding Bros [1912] 2 KB 94 Love Stewart Ltd v. Rowtor Steamship Co Ltd [1916] 2 AC 527, HL M Golodetz Co Inc v. Czarnikow-Rionda Co Inc, The Galatia [1980] 1 WLR 495, CA MacWilliam Co Inc v. Mediterranean Shipping Co SA, The Rafaela S [2003] 3 All ER 369 Martineaus Ltd v. Royal Mail Steam Packet Co Ltd (1912) 12 Asp MLC 190 MB Pyramid Sound NV v. Briese Schiffahrts GmbH Co KGMS Sina Latvian Shipping Association Ltd, The Ines [1993] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 492 Mediterranean Freight Services Ltd v. BP Oil International Ltd, The Fiona [1994] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 506, CA Mendala III Transport v Total Transport Corpn, Total International Ltd Addax Ltd, The Wilomi Tanana [1993] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 41 National Petroleum Co v. Athelviscoun t (Owners) (1934) 48 Ll L Rep 164 Norsk Bjergningskompagni A/S v. Pantanassa (Owners), The Pantanassa [1970] 1 All ER 848 Official Assignee of Madras v. Mercantile Bank of India Ltd [1935] AC 53, PC Oulu Osakayetio v. Arnold Laver Co [1940] 1 KB 750, CA President of India v. Metcalfe Shipping Co Ltd, The Dunelmia [1970] 1 QB 289, CA Re Denbigh, Cowan Co R Atcherley Co (1921) 90 LJKB 836, CA Re Keighley, Maxted Co Bryan, Durant Co (No 2) (1894) 70 LT 155 Re Salomon Co Naudszus (1899) 81 LT 325. Republic of India v. India Steamship Co Ltd (No 2) [1998] AC 878, HL Sewell v. Burdick (1884) 10 App Cas 74, HL Shipton, Anderson Co v. John Weston Co (1922) 10 Ll L Rep 762 SIAT di dal Ferro v. Tradax Overseas SA [1980] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 53, CA Silver v. Ocean SS Co Ltd [1930] 1 KB 416, CA Soon Hua Seng Co Ltd v. Glencore Grain Ltd [1996] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 398 Soproma SpA v. Marine Animal By-Products Corpn [1966] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 367 Spillers Ltd v. JW Mitchell Ltd (1929) 33 Ll L Rep 89 Sterns Ltd v. Vickers Ltd [1923] 1 KB 78, CA Suzuki Co v. Burgett Newsam (1922) 10 Ll L Rep 223, CA The Merak [1965] 1 All ER 230, CA The Nordglimt [1987] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 470 The Orteric [1920] AC 724, PC The Prinz Adalbert [1917] AC 586, PC The Skarp [1935] P 134 Thyssen Inc v. Calypso Shipping Corpn SA [2000] 2 All ER (Comm) 97 Transworld Oil (USA) Inc v. Minos Cia Naviera SA, The Leni [1992] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 48 Trucks Spares Ltd v. Maritime Agencies (Southampton) Ltd [1951] 2 All ER 982, CA Tsakiroglou Co Ltd v. Noblee Thorl GmbH [1962] AC 93, HL Waren Import Gesellschaft Krohn Co v. International Graanhandel Thegra NV [1975] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 146 Yelo v. SM Machado Co Ltd [1952] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 183 Table of Statutes Carriage of Goods by Sea Act 1992 Sale of Goods Act 1979